SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

10. The Ld.Counsel for the assessee opened arguments before the Bench with respect to ITA no. 1015/Chny/2012 which is an assessee’s appeal and submitted that Ground No.1 is general in nature and does not require separate adjudication. The Ld.CIT-DR did not raise any objection to dismissal of ground No. 1 raised by assessee in its appeal

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

10. The Ld.Counsel for the assessee opened arguments before the Bench with respect to ITA no. 1015/Chny/2012 which is an assessee’s appeal and submitted that Ground No.1 is general in nature and does not require separate adjudication. The Ld.CIT-DR did not raise any objection to dismissal of ground No. 1 raised by assessee in its appeal

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

38 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells reassess petitioner-assessee at higher rate in view of the presumptive rate prescribed under section 44AD has been sustained. In the case of Dr. Sahib Ram Giri v. ITO, (2008) 301 ITR 294 (Raj), the reassessment proceedings were initiated after recording reasons in writing by the AO. The non-availability

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

38 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells reassess petitioner-assessee at higher rate in view of the presumptive rate prescribed under section 44AD has been sustained. In the case of Dr. Sahib Ram Giri v. ITO, (2008) 301 ITR 294 (Raj), the reassessment proceedings were initiated after recording reasons in writing by the AO. The non-availability

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

38 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells reassess petitioner-assessee at higher rate in view of the presumptive rate prescribed under section 44AD has been sustained. In the case of Dr. Sahib Ram Giri v. ITO, (2008) 301 ITR 294 (Raj), the reassessment proceedings were initiated after recording reasons in writing by the AO. The non-availability

ASSISTANT COMMISSIONER OF INCOME TAX, COIMBATORE vs. KAMATCHIPURAM VELLINGIRI JAYARAMAN, COIMBATORE

Appeal of the revenue is dismissed, where as the Cross objection of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

10,21,250/- and added to the total income. Further, during reassessment proceedings, the assessee was also asked to furnish details of Other expenses to the tune of Rs.39,19,696/- vide notice u/s 142(1) dated 28.02.2022, with supporting vouchers, which were not produced. He produced a ledger for the same and the expenses were in Cash and intentionally

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

10. It is obviously beyond the ten year outer ceiling limit prescribed by the statute. The terminal point is year outer ceiling limit prescribed by the statute. The terminal point is year outer ceiling limit prescribed by the statute. The terminal point is the tenth year calculated from the end of the assessment year relevant the tenth year calculated from

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

10. It is obviously beyond the ten year outer ceiling limit prescribed by the statute. The terminal point is year outer ceiling limit prescribed by the statute. The terminal point is year outer ceiling limit prescribed by the statute. The terminal point is the tenth year calculated from the end of the assessment year relevant the tenth year calculated from

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

reassessment order passed under section 147 r.w.s. 144B of the Act, in the facts and circumstances of the case. 21 I.T.A. Nos.1667 to 1670/Chny/24 22. The ld. AR Shri G. Baskar, Advocate adopted the same arguments advanced in earlier assessment year 2014-15 in respect of “change of opinion”. He relied on the decision of Hon’ble High Court

PKD TRUST,CHENNAI vs. ITO, POLLACHI

Appeal stands dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita No.2053/Mds/2014 आयकर अपील सं./Ita Nos.1820 & 1819/Mds/2016 "नधा"रण वष" / Assessment Years : 2010-11 & 2012-13 M/S Pkd Trust, The Income Tax Officer, Pkd Matriculation School, V. Ward I(2) / Ward 1(1), Coimbatore Road, Pollachi. Pollachi – 642 001. Pan : Aaaap 1297 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

u/s 10(23C) of the Act without assigning proper reasons and justification. (3) The CIT(Appeals) erred in sustaining the assessment of `1,01,81,782/- in the computation of taxable total income without assigning proper reasons and justification. (4) The CIT(Appeals) failed to appreciate that there was no proper opportunity given before the passing of the impugned order

P.K.D.TRUST,CHENNAI vs. ITO, POLLACHI

Appeal stands dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita No.2053/Mds/2014 आयकर अपील सं./Ita Nos.1820 & 1819/Mds/2016 "नधा"रण वष" / Assessment Years : 2010-11 & 2012-13 M/S Pkd Trust, The Income Tax Officer, Pkd Matriculation School, V. Ward I(2) / Ward 1(1), Coimbatore Road, Pollachi. Pollachi – 642 001. Pan : Aaaap 1297 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

u/s 10(23C) of the Act without assigning proper reasons and justification. (3) The CIT(Appeals) erred in sustaining the assessment of `1,01,81,782/- in the computation of taxable total income without assigning proper reasons and justification. (4) The CIT(Appeals) failed to appreciate that there was no proper opportunity given before the passing of the impugned order

P.K.D.TRUST,CHENNAI vs. ITO, POLLACHI

Appeal stands dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita No.2053/Mds/2014 आयकर अपील सं./Ita Nos.1820 & 1819/Mds/2016 "नधा"रण वष" / Assessment Years : 2010-11 & 2012-13 M/S Pkd Trust, The Income Tax Officer, Pkd Matriculation School, V. Ward I(2) / Ward 1(1), Coimbatore Road, Pollachi. Pollachi – 642 001. Pan : Aaaap 1297 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

u/s 10(23C) of the Act without assigning proper reasons and justification. (3) The CIT(Appeals) erred in sustaining the assessment of `1,01,81,782/- in the computation of taxable total income without assigning proper reasons and justification. (4) The CIT(Appeals) failed to appreciate that there was no proper opportunity given before the passing of the impugned order

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

10. At the outset, the ld.counsel for the assessee, with permission of the Bench stated that the issue in this appeal of Revenue is falling under the proviso to section 147 of the Act and reopening of assessment u/s.148 of the Act. 11. Brief facts are that the assessee company filed its original return of income

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

10. At the outset, the ld.counsel for the assessee, with permission of the Bench stated that the issue in this appeal of Revenue is falling under the proviso to section 147 of the Act and reopening of assessment u/s.148 of the Act. 11. Brief facts are that the assessee company filed its original return of income

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

10. At the outset, the ld.counsel for the assessee, with permission of the Bench stated that the issue in this appeal of Revenue is falling under the proviso to section 147 of the Act and reopening of assessment u/s.148 of the Act. 11. Brief facts are that the assessee company filed its original return of income

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

10 -: expenditure paid to M/s. Sakshi Trade Link Pvt Ltd, no other addition can be made even in terms of Explanation 3 to Section 147 of the Act reliance in this regard was placed on the decision of Hon’ble Jurisdictional High Court in the case of Martech Peripherals Pvt Ltd vs. DICT & Anr (2017) 394 ITR 733. Without prejudice

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

10 -: expenditure paid to M/s. Sakshi Trade Link Pvt Ltd, no other addition can be made even in terms of Explanation 3 to Section 147 of the Act reliance in this regard was placed on the decision of Hon’ble Jurisdictional High Court in the case of Martech Peripherals Pvt Ltd vs. DICT & Anr (2017) 394 ITR 733. Without prejudice

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

10 -: expenditure paid to M/s. Sakshi Trade Link Pvt Ltd, no other addition can be made even in terms of Explanation 3 to Section 147 of the Act reliance in this regard was placed on the decision of Hon’ble Jurisdictional High Court in the case of Martech Peripherals Pvt Ltd vs. DICT & Anr (2017) 394 ITR 733. Without prejudice